OBJECTIVE:
Those involved with reorganizing private corporations need to consider a wide range of technical rules, develop a plan that meets the client’s objectives, navigate the practical challenges of implementing the plan, and communicate the plan to other professionals. This seminar provides a practical approach and guidance on identifying, planning, documenting, and implementing reorganizations of private corporate groups. Participants will apply this approach using mini cases throughout the seminar. A brief high-level review of Income Tax Act (ITA) sections and other common technical rules will be provided, but participants should have a good working knowledge of these rules. 

WHO WILL BENEFIT:
Although most tax professionals would benefit from this seminar, it particularly targets practitioners and managers involved in reorganizations or tax planning for groups of privately held companies.

LEARNING OUTCOMES:
By the end of this course, participants should be able to:

• identify problems with corporate structures and develop alternatives,
• identify and analyze income tax rules that can impact the proposed transactions, and
• prepare a structured plan to implement a reorganization.

CONTENT:

•  The collection and evaluation of client information and objectives
• The identification of alternatives and development of a plan
• A high-level review of key technical Income Tax Act provisions, including Section 85, QSBC rules, Section 55, Part IV tax, Stop-loss rules, and Attribution rules and TOSI
• Loss utilization and employee buy-in

PREREQUISITES:

•  An understanding of the basic Income Tax Act sections that are commonly used in reorganizations, including Sections 85 and 86, as well as related and associated corporation rules.
• Prior attendance in the seminars Corporate Restructuring – Fundamentals and Corporate Tax – Small Business Deduction & Private Corporate Groups is recommended.

COURSE LEADER: PETER MOREIRA, CPA, CGA